Second Edition WEAPONS of MASS DESTRUCTION

28
First Pages Second Edition WEAPONS of MASS DESTRUCTION and TERRORISM James J.F. Forest University of Massachusetts, Lowell Russell D. Howard Brigadier General USA (Ret.) Foreword by Ambassador Michael Sheehan for26229_fm_i-xxvi.indd iii for26229_fm_i-xxvi.indd iii 1/11/12 3:48 PM 1/11/12 3:48 PM

Transcript of Second Edition WEAPONS of MASS DESTRUCTION

Page 1: Second Edition WEAPONS of MASS DESTRUCTION

First Pages

Second Edition

WEAPONS of MASS DESTRUCTION

and TERRORISM

James J.F. ForestUniversity of Massachusetts, Lowell

Russell D. Howard Brigadier General USA (Ret.)

Foreword byAmbassador Michael Sheehan

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338

John McNabb

Chemical and Biological Threats against Public Water Systems 1

Water is essential for all forms of life, but it is also scarce and vulnerable. While roughly

71 percent of the Earth is covered by water, only 2.5 percent of it is fresh drinkable water;

the rest is salt water in the oceans. 2 Further, a significant proportion of fresh water is trapped

in glaciers and snow cover. Overall, water is a scarce commodity—less than 1 percent of

the Earth’s water is fresh water that is available to its nearly 7 billion people. 3 By some

estimates, 1.1 billion people in the developing world do not have access to clean drinking

water, 4 and this reduces food production, stifles economic growth, and leads to widespread

disease and death. 5 In the United States and other developed countries, industrial pollution,

stormwater runoff, waste disposal, and development pressures contaminate drinking water

supplies. For example, over 100 public water supply wells or wellfields have been closed

in Massachusetts 6 from 1960–1985 due to contamination.

Clearly, human survival depends on our ability to protect this vital resource. Drink-

ing water is widely viewed as a “critical infrastructure,” 7 but it is also important to note that

private companies are increasingly acquiring drinking water resources and infrastructure

which were previously publicly owned. This worldwide trend of increased privatization,

according to critics 8 , leads to higher water prices, increased stress on water resources, and

loss of democratic control over water resources. Today, water is a $400 billion global in-

dustry, 9 and some have called it “the new oil.”

The U.S. has some of the cleanest, safest drinking water in the world. It has been

decades since the U.S. has seen any outbreaks of cholera, dysentery, or other diseases

from contaminated drinking water that still occur in other parts of the world. A survey 10

conducted in 2010 by the engineering firm ITT found that 95 percent of American voters

value water over any other service they receive, including heat and electricity, nearly one in

four American voters is “very concerned” about the state of the nation’s water infrastruc-

ture, 29 percent of voters agree that water pipes and systems in America are crumbling and

approaching a state of crisis, 80 percent of voters say water infrastructure needs reform;

and about 40 percent say major reform is needed.

This chapter will describe how public water systems are vulnerable to attack from

chemical and biological threats and through their control systems. While history shows

that massive deaths from such attacks are difficult to accomplish, such attacks still have oc-

curred throughout thousands of years of recorded human history and continue to this day.

A successful attack on one or more public water system would have catastrophic effects

on public health and the economy. While some progress has been made since 9/11 to bet-

ter secure United States drinking water resources, significant vulnerabilities remain which

could be exploited by al Qaeda or other attackers.

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Chemical and Biological Threats against Public Water Systems 339

Intentional Contamination of Water Systems Drinking water has been the target of attacks for thousands of years. 11 Human history con-

tains a long list of attacks against drinking water, including:

• 500 BC: Assyrians poisoned the wells of their enemies with rye argot.

• 590–650 BC: Athenians threw roots of helleborus into a small river leading from

the Pleistrus River to Cirrha during a siege. The enemy forces became violently ill

and were defeated.

• 1462: Vlad the Impaler burned villages and poisoned his own wells to deny them

to the invading Turks.

• 1939–1942: Japan’s Unit 731 poisoned wells and reservoirs in Manchuria with

typhoid and other pathogens.

• 1945: Germans polluted a large reservoir in northwestern Bohemia with sewage.

• 1992: In Turkey, potassium cyanide was found in Turkish Air Force water; the

Turkish Workers Party, a terrorist group, claimed responsibility.

• 1998–1999: In Kosovo, Serbs disposed of bodies in wells to poison them.

• 2006: In Sri Lanka, Tamil Tiger rebels cut the water supply for government-held

villages; the government then attacked the reservoirs.

Homegrown Terrorist Attacks

U.S. drinking water supplies have also been attacked, including by homegrown terrorists

and others. 12 For example:

• 1844: A mob destroyed a reservoir in Mercer County, Ohio, that they considered a

health hazard.

• 1907–1913: A Los Angeles aqueduct was repeatedly bombed to prevent the diver-

sion of water from Owens Valley to Los Angeles.

• 1972: Two members of the militant cult “Order of the Rising Sun” were arrested

in Chicago with botulism, meningitis, anthrax and 30–40 kg of typhoid cultures

which they intended to use for poisoning water supplies in Chicago, St. Louis, and

other cities.

• 1977: A North Carolina reservoir was contaminated with an unknown poison

chemical, shutting down the reservoir.

• 1980: In Pittsburgh, water mains were contaminated with a weedkiller.

• 1984: Members of the Rajneesh religious cult planned to contaminate the Dalles,

Oregon city water storage tank with Salmonella, but instead they contaminated salad

bars in restaurants, causing an outbreak of 751 cases of Salmonella poisoning. 13

• 1985: Federal officials learned of a plot by the survivalist group The Covenant,

Sword and the Arm of the Lord to contaminate the water supplies of Chicago, New

York City and Washington, D.C., with a 30 gallon drum of potassium cyanide. 14

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340 Chapter 3.2 Chemical and Biological Threats

• 2003: In Greenville, North Carolina, ricin was found at a U.S. Postal Service office

with a written note threatening to poison the local water supply.

• 2003: In Michigan, four incendiary devices were found in a water bottling plant;

the Environmental Liberation Front (ELF) claimed responsibility.

Al Qaeda’s Intentions to Poison Drinking Water

There have also been several indications of al Qaeda’s interest in poisoning drinking water.

For example, a February 1995 letter by al Qaeda operative Ramzi Youssef, the leader of

the group that attacked the World Trade Center in 1993, contained a reference to poisoning

drinking water: “We also have the ability to make and use chemicals and poisonous gas

for use against vital institutions and residential populations and drinking water sources and

others.” 15 Other examples include:

• Documents seized by U.S. forces in 2001 at the Tarnak Farms al Qaeda training

camp near Kandahar, Afghanistan, showed plans to poison U.S. drinking water

and food supplies with pathogens. 16 The seized documents included biological

warfare books, manuals, letters, tutorials, fermenter photos, notes and other infor-

mation, indicating that the group had an active program to acquire biowarfare

agents and that they had sought cultures of the following pathogens: B. anthrax,

Salmonella typhi, S. paratyphi, Y. pestis, N. miningitus, B. mallei, Cl. Diptheria,

CL. Botulinum, B. abortus, and E. coli. 17

• In his 2002 State of the Union Address, President Bush said that the confiscated

al Qaeda documents in Afghanistan included maps of public water systems. “We

have found diagrams of American nuclear power plants and public water facili-

ties, detailed instructions for making chemical weapons, surveillance maps of

American cities, and thorough descriptions of landmarks in America and through-

out the world.” 18

• In early 2002, the FBI arrested two al Qaeda-connected individuals in the United

States with documents in their possession about poisoning U.S. drinking water

supplies. Then, on January 29, 2002, the National Infrastructure Protection Center

issued a bulletin (“Terrorist Interest in Water Supply and SCADA Systems” -

Information Bulletin 02-001) which described how “a computer that belonged to

an individual with indirect links to Osama bin Laden contained structural architec-

ture computer programs that suggested the individual was interested in structural

engineering as it related to dams and other water-retaining structures. In addition,

U.S. law enforcement and intelligence agencies have received indications that

Al-Qaeda members have sought information on Supervisory Control and Data

Acquisition (SCADA) systems available on multiple SCADA-related websites.

They specifically sought information on water supply and wastewater management

practices in the United States and abroad.” 19

• In February, 2002, Italian police uncovered what appeared to be a plot to poison the

water of the U.S. Embassy in Rome with cyanide. According to one media report,

“Italian police found approximately ten pounds of a chemical compound containing

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Chemical and Biological Threats against Public Water Systems 341

cyanide in an apartment in Rome with maps highlighting the U.S. embassy and

showing the city’s water system. When police discovered recently-made holes in

the underground passageways near the embassy, it looked like a serious threat had

been uncovered. However, press reports soon cited officials saying the chemical

likely would have become harmless once diluted by the water. Nine Moroccans

were arrested, but in April 2004, all were acquitted.” 20

• In 2003, Pakistani authorities arrested Majid Khan, a Pakistani national who was

a legal resident of the U.S., and charged him with plotting to poison U.S. drinking

water reservoirs, bomb gas stations, and conduct other terrorist acts for Al Qaeda.

Khan, who has denied the charges, is being held in Guantanamo. 21

• In September 2003, the FBI warned that terrorists might use two naturally occur-

ring toxins, nicotine and solanine, to poison U.S. food or water supplies. 22 Nicotine

is found in tobacco plants. Solanine—a toxic alkaloid—is found in nightshade,

eggplant, and green peppers, among other plants and vegetables. According to an

Associate Press report, this FBI bulletin details how “terrorist manuals and docu-

ments recovered at Al Qaeda sites in Afghanistan contain references to use of both

substances as poisons.” 23

• Documents found in Osama bin Laden’s compound in May, 2011, according to

ABC News, referenced various plots “to attack infrastructure targets such as water

supply and transportation including rail and air . . . In the past, al Qaeda planned

for attacks on water supplies have included an interest in mining dams and in poi-

soning water supply.” 24

• An al Qaeda member was arrested in Spain in August 2011 for threatening to poi-

son the water supplies of tourists to avenge Bin Laden’s death and also called for

such attacks to be made in Europe and the United States. It was also reported that

the suspect “had gone so far as to obtain manuals on poisons, toxins and explosives

on jihadist websites.” 25

These and other instances demonstrate an ongoing commitment among al Qaeda members

to attack public drinking water systems in the United States and elsewhere. It is thus vital

for homeland security professionals to recognize the various ways in which these systems

are vulnerable.

Physical Infrastructure Vulnerabilities

Fundamentally, the infrastructure of a local public water system, consisting of open reser-

voirs, wellfields, treatments plants, pump stations, and hundreds or thousands of miles of

distribution water mains with fire hydrants, is impossible to fully secure. An attack on the

entire national drinking water physical infrastructure at once is unlikely, highly improb-

able, if not impossible, because of the fragmented 26 nature of the infrastructure. Unlike the

inherently interconnected electrical infrastructure, where a fault or attack on one-two nodes

could bring down an entire grid, 27 water utilities are separate entities that would have to be

attacked one by one. Therefore the most hardened facilities would be the ones less likely

to be attacked.

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Another consideration is that each water utility is designed differently: each one is

based on specific local requirements based on water quality, location of water resources,

growth of the served community over time, and other factors. 28 They vary greatly in size,

from serving 25 persons at a time to many millions. There are over 160,000 29 separate

drinking water systems in the United States—about 55,000 are community water systems

and the rest are very small systems that serve either a small number of people all the time or

serve a transient population. While many have emergency interconnections to use for back-

up water in case of emergency, and some share water supplies, for the most part an attack

on one water system does not threaten any of the others. There has been some consolidation

in the U.S. water infrastructure, in the form of water companies that span multiple states.

American Water, the largest, serves 16 million people 30 in 1,600 communities and 35 states.

Their water facilities, however, are not physically connected, but their facilities are served

by the same computer network for administrative purposes. The other water conglomerates

include Aquarion Water and U.S. Water.

However, since about 90 percent of U.S. water utilities use chlorine for disinfec-

tion, that near universal use of chlorine could serve as a potential Achilles Heel. 31 About

38 percent of chlorine is produced in coastal Louisiana and is transported by rail from

there across the United States. 32 An adversary could therefore disrupt a significant portion

of U.S. drinking water production by attacking those chlorine plants or the rail lines they

use. A less likely but not impossible scenario is that if an adversary could contaminate a

significant amount of this chlorine with a radioactive substance, 33 then a significant number

of U.S. citizens could be poisoned all at once through this attack vector.

Another important factor to consider is that the physical infrastructure of the national

drinking water system 34 is crumbling. Decades of deferred maintenance have left the country

with thousands of miles of decaying 100-year-old water mains, clogged distribution systems

prone to frequent water main breaks, substandard and failing treatment plants, broken and un-

usable fire hydrants, and insufficient storage capacity to provide fire protection. The Ameri-

can Society of Civil Engineers gives the nation’s drinking water infrastructure a D- grade and

estimates that an investment of at least $220 billion 35 over the next 20 years is needed.

Water System Components

A drinking water utility is composed of four primary physical components: supply, treat-

ment, storage, and distribution:

• Water Supply. The source of the public water supply is from groundwater or sur-

face water. Groundwater is contained in an underwater reservoir or river called an

“aquifer” which is collected by pumping the water to the surface in a well or well

field. Surface water sources can be a natural body of water, such as a river, pond,

or lake, or an artificial body of water called a “reservoir” which was created by

the impoundment of water by a dam. An aquifer can be contaminated by direct

injection of pollutants into the well or into the aquifer, by leaking underground

storage tanks, or by runoff of pollutants into the surface area above an aquifer, the

area closest to the well being the most vulnerable. A surface water source can be

contaminated by direct dumping of pollutants into the water body or by runoff of

pollutants into the watershed area which drains into the water body.

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Chemical and Biological Threats against Public Water Systems 343

• Water Treatment. Typical treatment includes an intake of the source water,

flocculation/sedimentation to take out relatively large solid matter, addition of

alum to control pH, filtration to take out smaller solid matter, oxidation or ion

exchange to consume dissolved organic matter, reverse osmosis, ozonozation,

and chlorination to disinfect the water. The concentration of each of the treatment

chemicals added is paced according to the volume and rate of flow into the treat-

ment plant. The quality of the water leaving the plant can be adversely affected by

an increase or decrease in the proper amount of treatment chemicals, for example

if the chlorination pumps were turned off then the water would not be disinfected

and would threaten public health.

• Water Storage. One or more finished water storage tanks are used in a public water

supply system to store the unused water that had been pumped from the treatment

plant to distribution, and also to provide the required pressure to the distribution

system. The pressure is dictated by the difference in elevation from the top of

the water in the tank to the elevation of the pipe bringing water into a customer’s

dwelling. Tanks are typically composed of concrete or steel. Many systems moni-

tor the chlorine residual in the tanks, because if water is allowed to sit too long

in a tank the chlorine will decay, allowing the growth of pathogens which could

threaten public health.

• Water Distribution. The final step is the delivery of the finished water from the

treatment plant to the customer, via water mains and pipes, which are typically

made these days of ductile iron or plastic (older pipes were made of cast iron

or concrete asbestos). The distribution systems also includes many fire hydrants,

blowoffs (to allow flushing at the end of a pipe if there is no hydrant there), valves,

and the connections. Over time the water mains can become clogged with accumu-

lated sediment left over from the treatment process, valves can break from years

of wear and tear, and hydrants can freeze. The hydrants, blowoffs, and connections

are all potential locations for the entrance of contaminants from backflow pressure

if the pressure of a contaminated water source, say from a whole building sprinkler

system, exceeds the pressure of the distribution system. Backflow preventers are

usually required to be installed in such locations.

Actual Contamination Incidents

There are many examples of drinking water in public water systems which have been con-

taminated unintentionally through each of these components. For example:

• Water Source: In one of the most serious water contamination incidents in North

America in recent times, in May 2000, in Walkerton, 36 Ontario, seven people died

and hundreds became seriously ill from an E. coli contamination of their ground-

water supplies by a massive manure runoff from nearby farms.

• Water Treatment: On July 6, 1988, the inadvertent dumping of 20 tons of alu-

minum sulphate into the wrong tank at the water treatment plant in Camelford,

England, 37 killed at least 20 people and made thousands more very sick with alu-

minum poisoning.

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• Water Storage: The City of Woburn, Massachusetts, issued a boil water order 38

in March, 2007 because of animal waste that had gotten into the Rag Rock water

storage tanks, contaminating the water with E. coli bacteria. Woburn was also the

site of an earlier incident during the 1970s and early ’80s, in which the improper

disposing of industrial solvents by two corporations was linked to water contami-

nation in the groundwater pumped from wells G and H, contributing to an unusu-

ally high number of childhood leukemia cases, cancer and other health problems.

• Water Distribution: The EPA has compiled a list 39 of 459 backflow incidents in

water distributions systems in the U.S. that have resulted in 12,093 illnesses from

1970 to 2001. In a backflow incident, contaminated water from inside a building,

irrigation system, sprinkler system, etc. is siphoned into the public water system

resulting in contamination of the drinking water in the distribution system, leading

to illness and public health impacts.

Vulnerability Assessments

Although nothing should be ruled out entirely, the potential vulnerabilities of each compo-

nent are summarized in Table 1 .

Component Characteristics Vulnerability Assessments

Water

Supply

• Well fields. The source water is

underground and out of sight.

• Natural water bodies and

reservoirs. The source water is in

plain sight, exposed, but there is

a large volume of water.

• Dams create artificial reservoirs

by holding back large volumes

of water.

• Cost to monitor reservoir is very high and

not 100% effective

• Dams could be attacked with conventional

explosives to inundate populated areas, but

this does not poison drinking water.

• Reservoirs have a large volume of water

that would require large amount of

contaminant to overcome dilution.

• Reservoirs are difficult to monitor and

impossible to fully protect.

• Wells are potentially most vulnerable at the

well head where water is pumped out of the

aquifer, treated, as pumped to distribution.

• Wells could be intentionally contaminated

in the area adjacent to the well head where

surface water runoff drains into the aquifer,

but there is little certainty that this would

be effective. Since water goes next to

treatment, this reduces this vulnerability.

• Retention time of water can be weeks or

months, increasing the time for the

Table 1

Vulnerability Assessments of Water System Components

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Chemical and Biological Threats against Public Water Systems 345

contaminant agent to be further diluted

or degraded, and also delays the period

between the contamination and its effect.

• Well heads are usually enclosed, guarded,

and monitored regularly. However, the

well heads and pumping stations are

usually in remote locations which may not

be manned continuously and be monitored

only remotely.

• Overall, low risk

Water

Treatment

• Treatment plants are usually in

enclosed buildings with fencing,

video surveillance, and alarm

systems, and are relatively easy

to adequately protect.

• The most vulnerable point is

the clearwell, where finished

water is pumped directly to the

distribution system.

• Each treatment plant is unique.

• Since each plant is unique, any attack

would require substantial research & local

knowledge to change process to poison

water.

• There are multiple injection points in a

treatment plant that could be vectors of

attack.

• A conventional sabotage attack with

explosives could cripple a treatment

plant for weeks or months, especially

if the high lift pumps, which in most

cases are custom-made, are damaged or

destroyed.

• Highest potential for risk would be an

insider attack.

• Low risk.

Water

Storage

• Finished water storage tanks

collect water not used in

distribution for use when

treatment plant is not running.

• These also provide pressure to

the system equal to that provided

by the plant’s high lift pumps.

• Water in tank is after treatment and not

tested for more than coliform bacteria, so

contaminants unlikely to be detected.

• There are very few storage tanks in any

system so they are easy to adequately

guard.

• Access points for elevated tanks are at

the top of the tank, limiting the amount of

contaminant to what can be carried to the

top while avoiding detection.

• Low to Medium risk.

Water

Distribution

• Even a small utility will have

dozens of miles of water mains

and hundreds of fire hydrants.

• Large utilities will have hundreds

of miles of water mains and

thousands of fire hydrants.

• Every connection by a customer

to the system is a potential attack

vector.

• Water mains and hydrants are usually not

fully maintained because of costs.

• Impossible to fully protect all water mains

and hydrants from attack, too many of

them.

• Connections are underground and out of

sight, and are inside private property.

• Medium to High risk.

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346 Chapter 3.2 Chemical and Biological Threats

Effective Chemical, Biological and Radiological Agents for Drinking Water Contamination

According to analysis by Peter Gleick, a chemical, biological or radiological (CBR)

agent used for contaminating a drinking water supply must have several characteristics,

including:

• “Weaponized: it must be produced and disseminated in quantities sufficient to have

the intended effect.

• Appropriate for water dissemination: it must be viable, dissolvable, stable and

transportable in water.

• Infectious, virulent or toxic: it must be effective at causing illness or death, with no

widespread immunity in the target population.

• Effective over time and treatment: it must maintain its effectiveness in water long

enough to reach and affect humans and it must not be negated by standard water

treatment systems likely to be in place. 40

As reflected in Table 2 , there are a wide variety of CBR agents that meet these criteria and

could potentially be used to poison a public drinking water supply: 41

Class Examples (not exhaustive)

Microbiological contaminants

Bacteria Bacillus anthracis, Brucella spp., Burkholderia spp.,

Campylobacter spp., Clostridium perfringens, E. coli

O157:H7, Francisella tularensis, Salmonella typhi,

Shigella spp., Vibrio cholerae

Viruses Caliciviruses, Enteroviruses, Hepatitis A/E, Variola

Parasites Cryptosporidium parvum, Entamoeba histolytica,

Toxoplasma gondii

Inorganic chemicals

Corrosives and caustics Hydrochloric acid, sulfuric acid, sodium hydroxide

Cyanide salts or cyanogenics Sodium cyanide, potassium cyanide, amygdalin, cyanogen

chloride, ferricyanide salts

Metals Mercury, lead, osmium, their salts, organic compounds

and complexes (even those of iron, cobalt, copper are toxic

at high doses)

Non-metal oxyanions, organo non-

metals

Arsenate, arsenite, selenite salts, organoarsenic,

organoselenium compounds

Organic chemicals

Fluorinated organics Sodium trifluoroacetate (a rat poison), fluoroalcohols,

fluorinated surfactants

Table 2

Chemical and Biological Contaminants of Water

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As this table illustrates, acquiring at least one of these is not difficult, and some are

more difficult to acquire than others.

The Most Likely Physical Attack Scenario

The most likely attack vector is through the distribution system, which is the most vulner-

able 43 component of a public water system. While each component has vulnerabilities, as

discussed above, the consensus from a number of studies on this subject is that if the at-

tackers objective is to actually poison and kill the maximum amount of people, and not to

Hydrocarbons and their oxygenated and/or

halogenated derivatives Paint thinners, gasoline, kerosene, ketones,

alcohols, ethers (e.g. methyl tert-butyl ether or

MTBE), halohydrocarbons (e.g. dichloromethane,

tetrachloroethene)

Insecticides Organophosphates (e.g. Malathion), chlorinated organics

(e.g. DDT), carbamates (e.g. Aldicarb) some alkaloids

(e.g. nicotine)

Malodorous, noxious, foul-tasting,

and/or lachrymatory chemicals

Thiols (e.g. mercaptoacetic acid, mercaptoethanol),

amines (e.g. cadaverine, putrescine), inorganic esters (e.g.

trimethylphosphite, dimethylsulfate, acrolein)

Organics, water-miscible Acetone, methanol, ethylene glycol (antifreeze), phenols,

Detergents

Pesticides other than insecticides Herbicides (e.g. chlorophenoxy or atrazine derivatives),

rodenticides (e.g. super-warfarins, zinc phosphide,

a-naphthyl thiourea)

Pharmaceuticals Cardiac glycosides, some alkaloids, antineoplastic

chemotherapies, anticoagulants (e.g. warfarin). Illicit

drugs such as LSD, PCP and heroin

Chemical warfare agents

Chemical weapons Organophosphate nerve agents (e.g. sarin, tabun, VX),

vesicants, [nitrogen and sulfur mustards (chlorinated alkyl

amines and thioethers, respectively)], Lewisite

Biotoxins

Biologically produced toxins Biotoxins from bacteria, plants, fungi, protists, defensive

poisons in some marine or terrestrial animals. Examples

include ricin, saxitoxin, botulinum toxins, T-2 mycotoxins,

microcystins

Radiological contaminants

Radionuclides Does not refer to nuclear weapons. Radionuclides may

be used in medical devices and industrial irradiators

(cesium-137 iridium-192, cobalt-60, strontium-90).42 Class

includes both metals and salts.

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348 Chapter 3.2 Chemical and Biological Threats

merely threaten to poison the water or to disrupt water delivery, then the attack would be

directed through the distribution system.

In one recent study, researchers used a hypothetical “backflow attack” to demonstrate

the effects of a CBR agent on a water distribution system. Using this method, pumps such

as used by lawn chemical companies are used to inject chemicals (e.g., weed killer or some

other item listed in Table 2 above) into the distribution system. The injection point could

be any existing connection to the distribution system, such as a fire hydrant or a connection

in the basement of a building where the activity would not be immediately detected. The

pump used for this type of attack would need to exceed the pressure gradient of the water in

the systems water mains, usually around 80 pounds per cubic inch. It is estimated that us-

ing this method, a few gallons of a toxic agent could contaminate a system serving around

150,000 people in just a few hours. 44

According to a similar study published in the January 2005 Journal of the American Water Works Association, the attacker would need a detailed knowledge of the hydraulics

of the water distribution system, and the most effective method would be to use a slow

injection of the contaminants from a connection to a major distribution water main in the

distribution system over a long period of time. 45 This method could also be used to target a

specific building or facility. With knowledge of the hydraulic conditions in the distribution

system, and some calculations, an adversary could inject a relatively small amount of toxin

in a fire hydrant near the facility which would result in a lethal dose being received in the

water at that location.

To protect against such an attack, the water utility would need a “highly dense sys-

tem of detectors” 46 in its distribution systems, calibrated to look for general indicators of

water quality, such as conductance; such general indicators should be sufficient to detect

most forms of contamination that would be injurious to human health (but not all potential

agents). Also, as the authors of the 2005 study noted, if fire hydrants are to be located on

the main distribution mains they should be equipped with backflow preventers. In essence,

the only effective defense against attacks on a water distribution system is continuous real-

time monitoring of the quality of the water in the system. There are many such monitoring

systems on the market today, but so far very few water utilities have installed them because

of the cost and a perceived lack of urgent need for them.

Potential Al Qaeda Attack Scenarios

As noted above, al Qaeda members have repeatedly stated their intention to “poison” the

U.S. drinking water supply, and have conducted research and actively worked on develop-

ing poisons and means of delivering them. Of all the possible toxins or pathogens they

could potentially use, including those found in the Tarnak Farms documents, the one that is

the easiest for them to produce is ricin, made from castor beans.

According to the former Director of National Intelligence Dennis Blair in his 2010

Annual Threat Assessment, “if al-Qa’ida develops chemical, biological, radiological, or

nuclear (CBRN) capabilities and has operatives trained to use them, it will do so. Counter-

terrorism actions have dealt a significant blow to al-Qa’ida’s near-term efforts to develop

a sophisticated CBRN attack capability, although we judge the group is still intent on its

acquisition.” 47

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Al Qaeda members have shown a particular interest in ricin, a highly toxic biotoxin

which is weaponized, appropriate for dissemination in water, and is resistant to chlorina-

tion. Ricin is by far not the ideal waterborne poison, but its main advantage is that it is easy

to produce. Lesson 16 in the Al Qaeda Training Manual, 48 “Assassinations Using Poisons

and Cold Steel” provides instructions on how to extract the poison ricin from castor beans.

Ricin-making apparatus or traces of Ricin, and manuals with detailed instructions for mak-

ing and using Ricin, have been found in police raids on al Qaeda cells in Great Britain,

France, Spain, Russia, Georgia, Afghanistan, and Kurdish-controlled northern Iraq. 49

Assuming that al Qaeda still has sufficient manpower and funds to plan and carry

out an attack to poison the U.S. drinking water supply, how would they go about it? They

would not need to attempt to contaminate the entire water system of a city. Most likely

they would use the ricin (or other poison) in a specific targeted backflow attack on a key

building or facility which has high symbolic value and which would bring the maximum

publicity in addition to as many casualties that they could produce. Government agencies

must identify the most likely targets of such an attack, and take the necessary action to

secure prime target water supplies by installing backflow prevention devices and real time

contaminant monitoring, as well as securing the water supply connections to these facili-

ties. Clearly, al Qaeda has the motivation for mounting such an attack, and is actively seek-

ing the means to do so; they must be prevented from having any opportunity to succeed.

Response to a Water Contamination Incident

The first challenge in responding to a water contamination incident is knowing that an in-

cident is actually occurring. If the contamination was introduced in the distribution system

and there is no real-time contaminant monitoring (which is the case in almost all water

systems), then the first indication would be one or more people getting sick or dying. That

would bring them to the attention of the local doctor or hospital, who may or may not con-

nect the illness with a waterborne disease as opposed to another potential cause such as

food poisoning.

According to a recent study, most health care professionals have had limited or no

training in medical school or in their subsequent practice in recognizing waterborne dis-

eases. 50 The affected person may or may not recognize the source of their illness as their

drinking water. Any delay in recognizing that the illness has been caused by waterborne

agents will serve to increase the number of cases, further spread the agent through the water

system, and further delay the identification and management of the problem.

The Centers for Disease Control has called on the medical community to remain

vigilant, to observe and respond to unusual disease trends, and to detect and control inten-

tional contamination of public drinking water supplies. 51 An online resource 52 for health

care workers provides information to help them recognize and manage waterborne diseases

from intentional or natural causes. The website also contains information on Physician Preparedness for Acts of Water Terrorism, including clinically relevant information on wa-

terborne disease, and special risk communication and patient risk evaluation guidelines. 53

An intentional contamination of a public water system may be detected first by the

water utility, through its water testing or from an obvious security breach; perpetrators of

such an attack might also publicly announce the contamination. In such cases, it is clearly

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350 Chapter 3.2 Chemical and Biological Threats

important for the utility to involve the public health community. Both the water utility and

the local public health community must work together to identify and effectively respond

to the problem; the public health officials to treat the affected residents and the water utility

to take appropriate actions to contain and eliminate the contamination. 54

The United States Environmental Protection Agency (EPA) has prepared a number of

guidance documents to help local water utilities respond to drinking water contamination

threats and incidents, including:

• A Water Security Handbook: Planning for and Responding to Drinking Water

Threats and Incidents 55

• Response Protocol Toolbox: Planning for and Responding to Drinking Water

Contamination Threats and Incidents 56

• Emergency Response Plan Guidance for Small and Medium Community Water

Systems to Comply with the Public Health Security and Bioterrorism Preparedness

and Response Act of 2002 57

The Cyber Threat Dimension: Water System SCADA Control System Vulnerabilities Supervisory Control and Data Acquisition (SCADA) 58 is the term usually used to describe

the computerized central control system used in many drinking water utilities, as well as

in many other industrial, manufacturing, and energy facilities. SCADA replaced the legacy

control schemes which utilized electro-mechanical process control.

Historically, drinking water treatment facilities were isolated systems accessible only

through physical access to the valves, chemical feed units, and control panel in the water

treatment plant. In these legacy control systems, each valve, chemical feeder, and mecha-

nism was connected by individual wires to one or more central control panels where the

operator could view the many dials and meters showing the status of each component and

could change the settings individually as needed. Remote facilities like water storage tanks,

reservoir gates, and pump stations, were also connected through radio, telephone, cable, or

other means. However, in the past three decades many water utilities have retrofitted their

facilities by installing computer-controlled SCADA or other control system type hardware

and software. 59 The dedicated communications channels for remote facilities were in most

cases replaced by internet connections, 60 and also in many cases remote operation over the

internet of the SCADA system was implemented. A computer screen replaced the large

mechanical control panel with its dozens of dials, levers and mechanical registers.

SCADA systems were designed to provide consistent and reliable access; security

considerations were not in the forefront of design concerns. A public water system is ex-

pected to operate 24 hours a day, every day, setting the flow rate of water entering the plant,

automatically setting the amounts of treatment chemicals to keep pace with the flow rate,

and timing the flocculation, settling, and filtration phases to meet the required time periods

to be effective. As a results, the computer systems that control these actions are not de-

signed to be regularly updated with security patches (which often require a system to pause

services or even restart). Many water utility SCADA systems were designed in isolation,

but most of this kind of software runs on Microsoft Windows XP or Server 2003 systems. 61

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Some do not have regular internet access, but many do. Both of these factors contribute

to the vulnerability of drinking water facilities to intentional or unintentional intrusions. 62

By 2004, according to a report by the U.S. Government Accountability Office

(GAO), industrial control systems in general had become vulnerable because of 1) adop-

tion of standardized technologies with known vulnerabilities, 2) connectivity of control

systems with other networks, 3) insecure remote connections, and 4) widespread avail-

ability of technical information about control systems. 63 A March 2008 report by the

Water Sector Coordinating Council’s Cyber Security Working Group, lists a variety of

“water sector industrial control system risks today” including design limitations, more

open environments, increased connectivity and complexity, system accessibility, supply

chain limitations and information availability. 64 This report, Roadmap to Secure Control Systems in the Water Sector, 65 states that there are many ways in which a cyber event 66 can

affect a water system, “some with potentially significant adverse effects in public health,”

such as:

• Interfere with the operation of water treatment equipment, which can cause chemi-

cal over- or under-dosing

• Make unauthorized changes to programmed instruction in local processors to take

control of water distribution or wastewater collection systems, resulting in dis-

abled service, reduced pressure flows of water into fire hydrants, or overflow of

untreated sewage into public waterways

• Modify the control systems software, producing unpredictable results

• Block data or send false information to operators to prevent them from being aware

of conditions or to initiate inappropriate actions

• Change alarm thresholds or disable them

• Prevent access to account information

Further, the report notes that although many facilities have manual backup procedures in

place, the failure of multiple systems at once may overtax staff resources—even if each

failure is manageable by itself.

Other reports of note include the Project Grey Goose Report on Critical Infrastruc-ture: Attacks, Actors, and Emerging Threats, by Greylogic (June 2010), which describes

how state and/or non-state actors from China, Russia, and Turkey are “almost certainly”

targeting and penetrating the networks of energy providers and other critical infrastructure

in the United States and other countries, and projects that network attacks on the power grid

will escalate over the next 12 months. 67 A 2010 report by McAfee, based on a survey of 600

IT and security executives from critical infrastructures in 14 countries all over the world,

indicated that networks and control systems are under repeated cyberattacks, and that the

reported cost of downtime from major attacks is more than U.S.$6 million a day. 68 This

report also noted that 75 percent of control systems overall are connected to the internet

or other IP network, but in the water/wastewater sector only 55 percent are so connected;

only 33 percent of critical infrastructure services overall have policies that restrict or ban

the use of USB sticks or other removable memory; and that 77 percent of professionals in

the water/wastewater sector said that government regulation had either diverted resources

from improving security or had no effect.

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352 Chapter 3.2 Chemical and Biological Threats

Another report by McAfee, published in 2011, describes how many IT security exec-

utives at critical infrastructure facilities—including water supply facilities—in 14 countries

believe that their vulnerability had increased since the previous year, and concludes that

“they are not ready” for a cyberattack. 69 In addition, the report noted that 80 percent of the

executives said they had been hit with a large-scale Denial of Service (DDos) attack (an in-

crease over the 50 percent reported the previous year); 70 percent said they frequently found

dangerous malware on their systems; and 85 percent reported at least one network intrusion.

And in 2011 a report by the Department of Homeland Security concluded that in 2011 the

most commonly found vulnerabilities in industrial control systems were credentials man-

agement, weak firewall rules, and network design weaknesses. 70 These and other documents

illustrate how contemporary public water systems are vulnerable to a cyber attack.

Known Water System SCADA Cyber Attacks

There are only a handful of publicly disclosed SCADA cyber attacks involving drinking

water and wastewater facilities, including: 71

• 1994 –Salt River Project Water Dept., Arizona; 27-year-old hacker reportedly broke

into computers but was never in control of dams 72

• 2000 –Maroochy Water System, Australia; former consultant took control of wire-

less pump system 46 times to spill 264,000 gallons of raw sewage onto waterways.

• 2006 –Harrisburg, Pennsylvania water treatment plant; foreign hacker planted mal-

ware in plant computers to use them to distribute spam and pirated software

• 2007 –Tehema Colusa Canal Authority, California; former employee remotely

installed unauthorized software on a SCADA computer that controlled the flow of

water

• 2009 –Russian and Chinese spies have infiltrated the U.S. electric grids, mapping

the grids and planted bugs that could disrupt them, senior U.S. intelligence offi-

cials told the Wall Street Journal.

The Department of Homeland Security publishes a daily Open Source Infrastructure Re-

port 73 which summarizes incidents that often involve public water systems. In 2010, these

reports revealed a total of 914 “Water Sector” incidents, including 246 incidents at drinking

water treatment facilities. Of these, 71 involved water contamination, 79 were water main

breaks, 18 were chlorine leaks, 13 involved plant malfunctions, and 12 were incidents of

vandalism. There was only one reported incident of a “terrorist threat,” which turned out to

be a hoax. 74 Four incidents are of particular interest to this discussion, in that they involved

computer systems:

• March 2010: The public water system in Silver City, New Mexico, lost 3 million

gallons because of a water leak that investigators linked to a possible malfunction

in their newly installed SCADA system. 75

• June 2010: A computer failure caused the public water plant in Lake Chelan,

Washington, to stop operating. 76

• September 2010: A computer malfunction apparently shut down the water plant in

Glidden, Iowa and drained the town’s water storage tank. 77

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Chemical and Biological Threats against Public Water Systems 353

• December 2010: The water plant in New Canaan, Connecticut, was shut down

because of a computer malfunction, but water was still pumped into and through

the plant, causing flooding from the plant across the nearby roadway. 78

Finally, some incidents within the past year have served to heighten concerns over the

cyber security of drinking water facilities. In June 2011, an IT security professional per-

formed a penetration test for an unnamed Southern California water utility, and was able

to gain control of the utility’s chemical control systems in less than a day. The route of

exploitation was workers who were able to remote into the SCADA system from home. 79

In August 2011, another IT security professional giving a demonstration a the annual Black

Hat IT security conference in Las Vegas showed how to use Google to access the Pro-

grammable Logic Controller (PLC) of a water treatment plant pump, but he did not try to

remotely have it do anything. And a February 2011 report by McAfee described an event

which became known as Operation “Night Dragon,” 80 a “coordinated covert and targeted

cyberattacks . . . conducted against global oil, energy and petrochemical companies.” The

objective appeared to be theft of intellectual property and trade secrets.

But perhaps the most significant development within recent years—in terms of cy-

bersecurity and critical infrastructure—is the Stuxnet worm, the first malware specifically

designed to attack SCADA systems. Stuxnet potentially shows the way for a cyber attack

on a water treatment plants as well as other infrastructure SCADA systems.

The Powerful Stuxnet Worm

In June, 2010, the IT security world was rocked by the discovery by security firm Vi-

rusBlokAda of a powerful worm 81 which was showing up in control systems all over the

world. While it was first thought that Stuxnet was designed to steal trade secrets and intel-

lectual property, it was soon learned that even though Stuxnet was found in computers and

control systems all over the world, it affected only certain Siemens control systems used for

controlling centrifuges in the Iranian nuclear development program. Stuxnet is considered

a “game-changer” because it is the first known malware to effectively attack SCADA sys-

tems. It utilized four previously unknown vulnerabilities in the Windows operating system

used to run the Siemens’ control system software—a major accomplishment, since most

successful malware tend to exploit just one undiscovered vulnerability. Stuxnet was also

designed to successfully bridge the “air gap” supposedly protecting the Siemens systems:

in other words, the machines were not connected to the internet, but the worm was still

spread by using thumb drives as the delivery method.

In its Stuxnet Dossier, the IT security firm Symantec describes Stuxnet as “a threat

targeting a specific industrial control system likely in Iran, such as a gas pipeline or power

plant. The ultimate goal of Stuxnet is to sabotage that facility by reprogramming program-

mable logic controllers (PLCs) to operate as the attackers intend them to, most likely out

of their specified boundaries.” 82 The Dossier also described specific characteristics of Stux-

net, including that it self-replicates through removable drives, exploiting a vulnerability

allowing auto-execution; can spread through a vulnerability in the Windows Print Spooler;

attempts to bypass security products; contacts a command and control server that allows

the hacker to download and execute code, including updated versions; and fingerprints a

specific industrial control system and modifies code on the Siemens PLCs to potentially

sabotage the system.

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354 Chapter 3.2 Chemical and Biological Threats

While the objective of Stuxnet was apparently to damage the Iranian nuclear pro-

gram, its methodology could be applied, or its code could be altered, to attack other indus-

trial control systems such as those at a water treatment plant. Of course, it still would take

an enormous amount of reconnaissance and research to design a Stuxnet-like malware to

attack a water treatment plant, and a separate design may be needed for each individual

plant attacked, because of their uniqueness, but it’s possible. Perhaps only a nation-state

would have the resources to accomplish this (as has been surmised about Stuxnet), but

perhaps not. If that day comes, then the question becomes whether the water sector has the

capability to defend against an attack from malware delivered through USB drives; right

now, the answer to that question is an emphatic “No.”

Summary of the Cyber Threat to Public Drinking Water Systems

By spring 2011, about one year after the discovery of Stuxnet, there had been a plethora

of additional vulnerabilities discovered in SCADA systems used around the world and

in water utilities. The antivirus company Symantec reports 83 that there had been 15 new

SCADA vulnerabilities disclosed in 2010, one more than the 14 publicly disclosed vul-

nerabilities in 2009. In March, 2011, Italian security researcher Luigi Auriemma released

proof of concept code on 34 SCADA vulnerabilities to Bugtraq (an online repository of

software vulnerabilities), which was followed by many advisories from ICS-CERT (Indus-

trial Control Systems Cyber Emergency Response Team). These vulnerabilities, according

to Auriemma, 84 would allow an attacker to execute a program remotely on a SCADA sys-

tem with an internet connection, allow attackers to access stored data or to interfere with

the process control hardware that is run by the SCADA system.

Many other SCADA vulnerabilities have continued to be revealed during 2011. For

example, a Russian security firm, Gleg, has offered an exploit pack for SCADA systems

called SCADA  1  with 22 modules incorporating 11 previously unknown vulnerabilities.

There has been speculation that the release of Stuxnet could be followed by some

kind of modified “Son-of-Stuxnet”, based on the capability shown by the original Stux-

net. Witnesses testifying in a hearing in November 2010 before the Senate Committee on

Homeland Security and Government Affairs testified that variants of Stuxnet could be used

to attack other critical infrastructure, such as the power grid, transportation systems, or

water supplies. 85

Stuxnet could be leading the way 86 as the first “weaponized” malware, setting a prec-

edent for newer variants targeting different applications because:

(1) Stuxnet provided a “step-by-step cookbook” for SCADA malware design;

(2) There are many vulnerabilities in SCADA that have been discovered since Stuxnet,

and many more most likely remain to be discovered;

(3) Specific knowledge of the target process used by the PLC’s controlled by the SCADA

software isn’t necessarily needed; and

(4) The Stuxnet-type code that is now available provides the basic structure to remotely

control a SCADA process for whatever objective the attacker might want, the cus-

tomizations can be added as needed.

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Clearly, the United States does face potential cyber attacks, on our critical infrastruc-

ture and other assets, from nation states, terrorist networks, criminal groups, malicious

hackers, and others, as pointed out by Director of National Intelligence Dennis Blair in his

Annual Threat Assessment: “Malicious cyber activity is occurring on an unprecedented

scale with extraordinary sophistication.” 87 Almost a decade earlier, the CIA indicated in a

Senate hearing that they were alert to the possibility of al Qaeda and Sunni extremists plan-

ning cyberwarfare attacks against U.S. critical infrastructures:

Cyberwarfare attacks against our critical infrastructure systems will become an increas-

ingly viable option for terrorists as they become more familiar with these targets, and

the technologies required to attack them. Various terrorist groups—including al-Qa’ida

and Hizballah—are becoming more adept at using the Internet and computer technolo-

gies, and the FBI is monitoring an increasing number of cyber threats. . . . These groups

have both the intentions and the desire to develop some of the cyberskills necessary to

forge an effective cyber attack modus operandi. 88

As noted earlier, there is evidence that al Qaeda has been researching SCADA and control

system used in drinking water and wastewater, as previously mentioned. However, most

observers conclude that al Qaeda does not have the skills, manpower, or technical sophis-

tication to carry out a cyber attack on critical infrastructure, or any other cyber attack. One

reason is that most of their key computer experts have been captured or killed. 89 Doro-

thy Denning, of the Center on Terrorism and Irregular Warfare at the Naval Postgraduate

School, has been closely examining this issue for many years, and recently concluded that

“Terrorists have not yet demonstrated that they have the knowledge and skills to conduct

highly damaging attacks against critical infrastructures (e.g. causing power outages) al-

though there are a few indicators showing at least some interest .  .  . At least in the near

future, bombs remain a much larger threat than bytes.” 90

Securing the Water Sector Responsibility for the security, maintenance, and operation of a local water utility is prin-

cipally the sole responsibility of that utility, subject to applicable local laws & regulations,

the state regulatory authorities, and the U.S. Environmental Protection Agency (EPA).

Homeland Security Presidential Directive 9 (HSPD9) directed the EPA to develop a sur-

veillance and monitoring program to provide early warning detection of a terrorist attack

using biological, chemical or radiological (CBR) weapons:

The Water Security (WS) initiative is a U.S. Environmental Protection Agency (EPA)

program that addresses the risk of contamination of drinking water distribution sys-

tems. EPA established this initiative in response to Homeland Security Presidential

Directive 9, EPA deployed the first full-scale, comprehensive CWS pilot in partnership

with the City of Cincinnati at the Greater Cincinnati Water Works (GCWW). Planning

and pre-design activities for the pilot began in December 2005, were substantially com-

pleted in June 2009, and data collection concluded in June 2010. The drinking water

CWS components are fully operational, with performance data continuing to be evalu-

ated by EPA. EPA awarded funding for CWS pilots in New York City, San Francisco,

Philadelphia, and Dallas. These four additional pilots were selected through a national

competition and will conclude in 2012. 91

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356 Chapter 3.2 Chemical and Biological Threats

In addition, the Bioterrorism Preparedness and Response Act of 2002 (P.L. 107-188,

42 U.S.C. 300i) amended the Safe Drinking Water Act 92 to require community water sys-

tems serving more than 3,300 individuals to complete a vulnerability assessment, prepare

an emergency response plan, and to submit them to the EPA. These vulnerability assess-

ments 93 had only one question regarding general PC security (passwords, etc.) and did not

address control system security. Furthermore, neither the Bioterrorism Act, nor any other

federal law or regulation require any water utility to actually make security upgrades to ad-

dress vulnerabilities; provide funds to help water utilities to make security improvements;

or require water utilities to revise or update the vulnerability assessment or emergency

response plan after they were completed in 2003-2004.

The progress of U.S. drinking water systems in improving their overall security was

assessed in a talk 94 given at the September 21, 2010 American Waterworks Association

(AWWA) Water Security Congress. The metrics used to assess this progress were devel-

oped by the Critical Infrastructure Partnership Advisory Council (CIPAC) and were col-

lected & aggregated by the Water Information Sharing and Analysis Center (WaterISAC).

According to their study:

• More than 70 percent had incorporated security planning and design programs to

all assets and facilities.

• More than 90 percent secure and monitor perimeters and have chemical safeguards

in place.

• More than 80 percent control access to restricted areas by screening/inspecting

people/vehicles who enter.

• More than 94 percent secure and monitor shipping, receipt and storage of hazard-

ous chemicals.

• More than 85 percent integrated security and preparedness into budgeting, training

and manpower responsibilities.

• More than 90 percent have developed emergency response plans.

• More than 50 percent are training, exercising, reviewing, and updating those plans.

• 75 percent are networking for collaborative responses in an incident.

• 86 percent have backup power for 24 hours; 50 percent for 96 hours (4 days) or more.

• 66 percent of water utilities can provide 91–100 percent of minimum daily demand

for 24 hours.

• Almost 33 percent of water utilities can provide 91–100 percent of minimum daily

demand for 72 hours. 95

However, it is important to note that of the “22 Sector Specific Measures” which were used

in this assessment, none of them addressed SCADA or Cyber security.

The good news is that there has been some progress in developing new resources to

assist local water utilities to protect against cyber and other attacks. For example:

• Water ISAC. The Water Information Sharing and Analysis Center is “a highly

secure Internet portal that provides the best source for sensitive security infor-

mation and alerts to help America’s drinking water and wastewater community

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protect consumers and the environment.” It is not a government program but was

developed under a grant from the EPA by the Association of Metropolitan Water

Agencies, as a resource to drinking water and wastewater utilities .96

• Training, information, and workshops on security issues are provided through the

United States EPA, American Water Works Association, Water ISAC, and other

affiliated organizations.

• Cyber Security Evaluation Tool (CSET), which is “a desktop software tool that

guides users through a step-by-step process to assess their control system and

information technology network security practices against recognized industry

standards. The output from CSET is a prioritized list of recommendations for

improving the cybersecurity posture of the organization’s enterprise and industrial

control cyber systems.” 97

• Threat Ensemble Vulnerability Assessment (TEVA) –program developed by the

EPA, Sandia National Laboratories, and others to provide tools, software, and

guidance to assist water utilities to implement real time monitoring for contami-

nants in the distribution system.

The American Water Works Association in 2004 estimated 98 that at least $1.6 billion is

needed for public water systems to implement just the recommended first steps (fences,

locks, etc.) in improving security, based on the vulnerability assessments. However, the

federal government has not provided funding for this, and existing federal and state finan-

cial assistance to water utilities does not include funding for security improvements.

Securing the Control Systems

In March 2008, the Water Sector Coordinating Council Cyber Security Working Group

published a Roadmap to Secure Control Systems in the Water Sector which “presents a

vision and supporting framework of goals and milestones for reducing the risk of ICS

[Industrial Control Systems] of the next ten years.” 99 The Roadmap identifies the follow-

ing as some of the “challenges” to reaching its goal to develop and deploy ICS security

programs:

• Limited executive recognition of ICS security threats and liabilities.

• Lack of awareness about ICS security risks.

• Business case for ICS security has not been established throughout the water

sector.

• Difficult or impossible to integrate new technologies into legacy systems.

• Implementation of security measures is often time consuming.

The “strategic framework” in the Roadmap seeks to achieve four main goals:

1) develop and deploy ICS security programs, 2) assess risk, 3) develop and implement

risk mitigation measures, and 4) partnership and outreach. The Roadmap also describes 18

near-term (0-1 year) milestones, including “isolate ICS from public switch networks” and

“Replace default security passcodes,” but there are no “progress reports” available any-

where that detail how many of these milestones, if any, have been accomplished.

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Serious Gaps Remain

While some progress has been made to better secure the U.S. drinking water infrastructure

following 9/11, there are several serious gaps that need to be addressed. To begin with, the

Bioterrorism Act does not provide clear lines of authority ,100 leading to some administra-

tive overlap, duplication of effort, and confusion of roles between the EPA and Homeland

Security. Neither the EPA nor Homeland Security has legal authority to order any water

utility to take action to improve their security. Each water utility makes its own decision on

whether to spend money if it has it to increase security.

Water utilities so far have only been required to complete a Vulnerability Assess-

ment and an Emergency Plan—but have not been required to take any action to address the

deficiencies revealed in their assessments. Further, these assessments do not adequately ad-

dress terrorist threats but were designed to address more traditional and less costly threats

such as vandalism and disgruntled employees. The EPA has not yet issued standards to the

water utility community around which they can develop a baseline for water security. 101

And there is no requirement that these Vulnerability Assessments or Emergency Plans be

updated or reviewed following their completion in 2003-2004. Most likely they are gather-

ing dust on shelves all over the United States. Since the Vulnerability Assessments were

exempted from state Freedom of Information Acts, no one outside the report writers and

utility managers know what the vulnerabilities were or the status of any actions to address

them. The information from Vulnerability Assessments has not been used to identify water

security research needs or to allocate funds to water utilities to make needed security im-

provements.

These efforts also require funding, but not enough money has been made available

to complete the Vulnerability Reports. While the maximum grant to a utility for complet-

ing an Assessment was capped at $115,000, the estimated cost for a very large utility to

complete one was in the millions. 102 No federal funds have been made available to actually

implement the recommendations of these Assessments, and there has been no overall as-

sessment of how much this exercise may have made water utilities safer.

Finally, there is insufficient research on effects of chemical and biological weapons

in drinking water, and how to best respond to such an attack on the water supply. Current

practices for routine monitoring of water supplies for contaminants are inadequate for

detecting chemical or biological contamination. 103 There has not been a strategic analysis

on the national level of what it would actually take to achieve security—and what the

metrics for that should be—for the national drinking water infrastructure. 104 These and

other challenges must be mitigated in the years ahead if we are to avoid a major catas-

trophe involving the exploitations of the public water sector vulnerabilities identified in

this discussion.

Conclusion As summarized in Table 3 , public water systems in the United States are vulnerable to at-

tack by chemical and biological weapons and through their SCADA control systems.

While some progress has been made since the attacks on American on September 11,

2001, to strengthen the security of public water systems, serious gaps remain.

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Chemical and Biological Threats against Public Water Systems 359

While public water systems nationally are facing a $220 billion shortfall over the

next 20 years in the necessary funds to properly maintain and upgrade their physical as-

sets, there is no funding program to provide to them the $1.6 billion (minimum) required to

make essential security improvements to counter the known vulnerabilities. This funding

should include the installation of real-time contaminant monitoring systems in water utili-

ties nationwide, and the needed research on the impact of CBR agents in water and how to

respond to a CBR contamination of a water supply.

Furthermore, as the Roadmap reveals, many water utility managers feel that the busi-

ness case has not been made for the need to increase the security of their SCADA control

systems. However, the development of Stuxnet and it’s inevitable progeny, in addition to

the inherent insecurity of water utility control systems, leave many water utilities wide

open to cyber attack. Strong federal action is needed to put some teeth into the Roadmap

process and to require water utilities to assess their vulnerabilities with their control sys-

tems and to address those deficiencies—with federal funding to help them get that done.

Action by Congress is needed to give the EPA the legal authority—and funding—to

direct every water utility to take the action necessary to strengthen their physical and cyber

security, to install real-time distribution system monitoring, and to implement the recom-

mendations to remedy the vulnerabilities revealed in the vulnerability assessments and

subsequent vulnerability reviews.

Finally, a strategic analysis on the national level needs to take place to define in

concrete terms what it would actually take to achieve security in the drinking water infra-

Potential Locations105

(1) At the source of water supply

(2) At the water treatment plant

(3) During storage of treated water (in the clear well, which is the reservoir in the plant which

stores the finished water before being pumped to distribution)

(4) In the distribution system (mains, pipes, hydrants, blow-off valves, pump stations)

(5) In a buildings plumbing system, holding tanks, whole building water treatment system

(6) Through cyber attacks on the water systems SCADA control system network

(7) Through interdependencies (treatment chemicals, electrical power, etc.)

Potential Types of Attacks

(1) Chemical contamination

(2) Biological contamination

(3) Physical disruption

(4) SCADA disruptions

Table 3

Summary of Potential Locations and Types of Attacks

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360 Chapter 3.2 Chemical and Biological Threats

structure, and the metrics for measuring the progress to that goal, with sufficient funding

to accomplish it. Failure to do so could result in a major attack on our national drinking

water through their cyber assets or the CBR equivalent of a 9/11 attack on the quality of

our drinking water.

John McNabb is President of InfraSec Labs. He was an elected Water Commissioner in Cohasset, Mass. for 13 years, and has worked at the Massachusetts. Department of Environmental Protection and Clean Water Action. He has published several papers on water infrastructure issues and has presented papers at several technical conferences, including Black Hat and DEFCON.

Notes 1. This paper is an update and expansion of the subjects covered in the authors’ DEF CON 18

presentation, Cyberterrorism and the Security of the National Drinking Water Infrastructure, http://www.defcon.org/images/defcon-18/dc-18-presentations/McNabb/DEFCON-18-McNabb-Cyberterrorism-Drinking-Water.pdf . The video of the talk can also be found on YouTube.

2. “ Water in the Universe ” by Vincent Kotwicki, Hydrological Sciences, Vol. 36, No. 1, February, 1991. He also points out that there are three theories of the origin of water on Earth (1) condensation of the early atmosphere, (2) outgassing from the interior of the primordial Earth, and (3) bombardment from comets and other extraterrestrial objects. Note that while the cometary bombardment theory has been very popular, it has been called into question by recent studies which show that the proportion of heavy water, called deuterium, found in cometary water are different than those found in the Earth’s water. “ Earth’s water probably didn’t come from comets, Caltech researchers say” http://neo.jpl.nasa.gov/news/news008.html

3. Wolf, Aaron T. (2001) “Water and Human Security,” Journal of Contemporary Water Research and Education: Vol. 118: Iss. 1, Article 5. Available at: http://opensiuc.lib.siu.edu/jcwre/vol118/iss1/5

4. “ Water Scarcity & Climate Change: Growing Risks for Businesses & Investors ” A Ceres Report, The Pacific Institute, February, 2009.

5. “ Meeting the MDG drinking water and sanitation target: the urban and rural challenge of the decade. ” World Health Organization and UNICEF, 2006.

6. Massachusetts Ground-Water Quality, National Water Summary, 1986, pp. 297–304. http://wellowner2.org/SWQP/GWQ_Massachusetts.pdf

7. Critical infrastructure is defined in the Patriot Act (P.L. 107–56) as “ systems and assets, whether physical or virtual, so vital to the United States that the incapacity or destruction of such systems and assets would have a debilitating impact on security, national economic security, national public health or safety, or any combination of those matters ” (Sec. 1016(e)).

8. “ Money Down the Drain: How Private Control of Water Wastes Public Resources, ” Food & Water Watch, Washington, DC, February 2009.

9. “ Water: The Next Oil or an Infrastructure Play? ”, Advisor Perspectives, 2008. http://www.advisorperspectives.com/pdfs/Water-The_Next_Oil_or_an_Infrastructure_Play.pdf

10. ITT Value of Water Survey, October, 2010. http://www.itt.com/valueofwater/media/ITT%20Value%20of%20Water%20Survey.pdf

11. See Water Conflict Chronology, Peter Gleick. http://www.worldwater.org/conflictchronology.pdf

12. See “ Water and terrorism ” by Peter Gleick, http://www.pacinst.org/reports/water_terrorism.pdf 13. For more on this attack, see the chapters by Bruce Hoffman, James Forest and Adam Dolnik in

this volume. 14. See Jonathan Tucker, Toxic Terror: Assessing Terrorist Use of Chemical and Biological

Weapons (MIT Press, 2000) 15. al-Qaeda/al-Ablaj Threat Assessment v1.0 PUBLIC RELEASE VERSION 30 May 2003

02:00:01 EST / 07:00:01 GMT, by Ben Venzke, IntelCenter, Alexandria, VA http://www.intelcenter.com/ATA-PUB-v1-0.pdf.

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Chemical and Biological Threats against Public Water Systems 361

16. “ Food Defence Incidents 1950–2008: A Chronology and Analysis of Incidents Involving the Malicious Contamination of the Food Supply Chain ” by G. R. Dalziel, Centre of Excellence for National Security (CENS), S. Raratnam School of International Studies, Nanyang Technological University, Singapore, 2009

17. “ FBI: Biosecurity and the Select Agent Program ”, presentation at the Select Agent Program Workshop, National Animal Disease Center, Ames, Iowa, May 10, 2011. http://www.selectagents.gov/resources/12.Will_So_FBI_SAP_workshop_Ames_5-10-2011.pdf

18. See Transcript of Presidents Bush’s State of the Union address, at: http://www.washingtonpost.com/wp-srv/onpolitics/transcripts/sou012902.htm

19. A copy of this bulletin is available online at: http://www.mrws.org/Terror/Bulletin.html 20. Chronology: the Plots. http://www.pbs.org/wgbh/pages/frontline/shows/front/special/cron

.html 21. See “From Baltimore Suburbs to a Secret CIA Prison,” Washington Post (September 10,

2006), online at: http://www.washingtonpost.com/wp-dyn/content/article/2006/09/09/AR2006090901024.html

22. “ FBI: Al Qaeda Might Use Poison ” http://www.cbsnews.com/stories/2003/09/05/national/main571778.shtml

23. “FBI Hunts 4 Terror Suspects,” CBS News (September 7, 2003), online at: http://www.cbsnews.com/stories/2003/09/07/national/main571952.shtml

24. Osama Bin Laden Raid: Al Qaeda ‘Playbook’ Revealed, ABC News, May 6, 2011. http://abcnews.go.com/Blotter/osama-bin-laden-raid-al-qaeda-playbook-revealed/story?id 5 13544154

25. “ Al-Qaeda suspect ‘plotted to poison water ” http://mg.co.za/article/2011-08-20-alqaeda-suspect-plotted-to-poison-water/

26. Challenges In The Water Industry: Fragmented Water Systems, American Water, http://www.amwater.com/files/FragmentedWaterSystems012609.pdf

27. Wang, Jian-Weng and Li-Li Rong, Cascade-based attack vulnerability on the US power grid, Safety Science, Volume 47, Issue 10, December 2009, pp. 1332–1336.

28. “ Drinking Water Treatment Plant Design Incorporating Variability and Uncertainty ”, Dominic L. Boccelli; Mitchell J. Small; and Urmila M. Diwekar, Journal of Environmental Engineering, 133:3, March 2007, pp. 303–312.

29. “ Drinking Water: Experts’ Views on How Future Federal Funding Can Best Be Spent to Improve Security ” United States General Accounting Office, GAO-04-29, October, 2003.

30. “ A Secure and Resilient Water Sector ” presentation by Don Correll, President & CEO American Water, at US Chamber - Global Water Summit, March 18, 2010.

31. See Chlorine: the Achilles Heel? Presentation at the 2009 American Water Works Security Congress, by John McNabb. http://www.cohassetwater.org/pdf/chlorine_achilles_heel.pdf

32. Vulnerability of Concentrated Critical Infrastructure: Background and Policy Options, Updated September 12, 2008, Paul W. Parformak, Congressional Research Service, RL33206, page CRS-4. http://www.fas.org/sgp/crs/homesec/RL33206.pdf

33. Proceedings of the First Annual Water Security Summit, December 3-4, 2001, Hartford, CT, Haasted Press, see page 196 and then listen to the recorded session.

34. See Analysis of the Massachusetts Drinking Water Infrastructure by John McNabb, presented at the September 18, 2008 New England Water Works Conference, http://www.newwa.org/PDF/AnnConf08-SessC1040.pdf , and published in the December, 2010 Journal of the New England Water Works Association, http://www.southshorepcservices.com/Analysis_Mass_Water_Infrastructure-NEWWA-Dec2010.pdf

35. Report Card on America’s Infrastructure, American Society of Civil engineers, http://www.infrastructurereportcard.org/fact-sheet/drinking-water . “ drinking water systems face an annual shortfall of at least $11 billion in funding needed to replace aging facilities that are near the end of their useful life and to comply with existing and future federal water regulation s.”

36. Fatal Disease Outbreak from Contaminated Drinking Water in Walkerton, Canada, Steve E. Hrudey, Association of Environmental Engineering & Science Professors Case Studies Compilations, 2006.

37. The Legend of Camelford: Medical Consequences of a Water Pollution Accident, Editorial by Anthony S. David and Simon C. Wessely, Journal of Psychosomatic Research, Vol. 39, No. 1, pp. 1–9, 1995.

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38. Boil order lifted, Woburn Advocate, March 6, 2007. http://www.wickedlocal.com/woburn/local_news/x1108312282#axzz1XEuSJnj4

39. Potential Contamination Due to Cross-connections and Backflow and Associated Health Risks, US EPA, September 27, 2001.

40. Water and Terrorism, Peter Gleick, Water Policy 8 (2006) 481–503, http://www.pacinst.org/reports/water_terrorism.pdf

41. Water and Terrorism, pp. 494–495. 42. Please see the chapters in this volume by James Forest, Charles Ferguson and Joel Lubenau for

more information about radiological materials. 43. GAO-04-29, DRINKING WATER: Experts’ Views on How Future Federal Funding Can Best Be

Spent to Improve Security, October, 2003. 44. Kroll, Dan., “ Water distribution monitoring: opportunities and challenges for enhancing water

quality and security. ” Hach Homeland Security Technologies White Paper July 2010, http://www.hachhst.com/wp-content/uploads/2010/07/White-Paper_-Enhancing-Security-in-Water-Distribution-System.pdf

45. Allman, pp. 2–3 . 46. Allman, pp. 2–3. 47. Dennis C. Blair, Director of National Intelligence, “Annual Threat Assessment of the U.S.

Intelligence Community for the Senate Select Committee on Intelligence,” Statement for the Record, (February 2, 2010). Online at http://ww.dni.gov/testimonies/20100202_testimony.pdf

48. Al Qaeda Training Manual, Pavilion Press, 2006, pp. 120–124. 49. An Al Qaeda Chemist and the Quest for Ricin, by Joby Warrick, The Washington Post, May 5, 2004,

page A01. http://www.washingtonpost.com/ac2/wp-dyn?pagename 5 article&contentId 5 A2159-2004May4

50. Recognizing waterborne disease and the health effects of water contamination: a review of the challenges facing the medical community in the United States, Patricia L. Meinhardt, Journal of Water and Health, 04.Suppl, 2006, pp. 27–34.

51. Ibid. 52. See the website at http://www.WaterHealthConnection.org 53. Recognizing Waterborne Disease and the Health Effects of Water Pollution: A Physician On-

Line Reference Guide, www.WaterHealthConnection.og 54. Linking Public Health and Water Utilities to Improve Emergency Response, R.J. Gelting and

M.D. Miller, Journal of Contemporary Water Research and Education, Issue 129, October, 2004, pp. 22–26.

55. Online at http://www.epa.gov/watersecurity/pubs/water_security_handbook_rptb.pdf 56. Online at http://www.epa.gov/watersecurity/pubs/rptb_response_guidelines.pdf 57. Online at: http://www.epa.gov/safewater/watersecurity/pubs/small_medium_ERP_guidance

040704.pdf 58. SCADA usually refers to highly distributed systems to control geographically dispersed

facilities, and the term Distributed Control Systems (DCS) usually refers to the control systems in a localized facility such as a single treatment plant. However, we will use the term SCADA as a generic term to be inclusive of the larger systems as well as the localized systems, since for the purposes of this paper the same factors apply to a full-fledged SCADA as do to a DCS.

59. For a detailed description of the technological transition, see C4 Security, The Dark Side of the Smart Grid–Smart Meters (in)Security, (September 2009), online at: http://www.c4-security.com/The%20Dark%20Side%20of%20the%20Smart%20Grid%20-%20Smart%20Meters%20%28in%29Security.pdf

60. Many of them, however, still retain “always on” modem connections using phone lines, another potential route of attack by attackers who perform “wardialing” to find active modems and then exploit them.

61. “ Improving Security for SCADA Control Systems ” Mariana Hentea, Interdisciplinary Journal of Information, Knowledge, and Management, Volume 3, 2008, pp. 73–82.

62. GAO-04-354, Critical Infrastructure Protection: Challenges and Efforts to Secure Control Systems, March 2004 .

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Chemical and Biological Threats against Public Water Systems 363

63. “ Critical Infrastructure Protection: Challenges and Efforts to Secure Control Systems ”, United States General Accounting Office, GAO-04-354, March 2004.

64. Roadmap to Secure Control Systems in the Water Sector (March 2008), p. 14. Available online at: http://www.awwa.org/files/GovtPublicAffairs/PDF/WaterSecurityRoadmap031908.pdf

65. Ibid . 66. The term “cyber event” is a broad term meant to encompass both unintentional and intentional

compromise of a system from malware. 67. Online at: http://dataclonelabs.com/security_talkworkshop/papers/25550091-Proj-Grey-Goose

-report-on-Critical-Infrastructure-Attacks-Actors-and-Emerging-Threats.pdf 68. In the Crossfire Report, Mcafee, January 28, 2010 69. In the Dark - Crucial Industries Confront Cyberattack, McAfee and CSIS, April 18, 2011 . 70. Common Cybersecurity Vulnerabilities in Industrial Control Systems, Control Systems Security

Program, National Cyber Security Division, Department of Homeland Security, May 2011. 71. Ibid . 72. It should be noted that this story is in dispute . 73. DHS only makes the last 10 reports available on their web site. I was able to obtain past reports

from the repository maintained by Bob Johnston, CISSP http://dhs-daily-report.blogspot.com/ , who has been downloading and storing the reports since 2004.

74. The incident reporting in these reports is not exhaustive, so one should not assume that these are all the incidents that actually occurred or that these numbers are representative of the actual incidence nationwide during 2010.

75. Silver City Sun News, March 11, 2010. DHS Open Source Report, March 12, 2010, p. 13. 76. Lake Chelan Mirror, June 23, 2010 http://lakechelanmirror.com/main.asp?SubSectionID 5 5

&ArticleID 5 2670&SectionID 5 5 77. Associated Press, September 20, 2010. http://www.whotv.com/news/who-story-glidden-water

-tower-092010,0,1010748.story 78. New Canaan Patch, December 4, 2010. http://newcanaan.patch.com/articles/computer-glitch

-shuts-down-water-plant 79. Marc told the author that “.  .  . it was a rather straight forward pen test just compromising

a series of systems using your standard Adobe and Microsoft related vulnerabilities. They suffered from the same problem as most places in that the actual control systems are not really ever patched, because of all the usual red-tape, which makes them easy to hack and really the only hard part was trying to find the private network (attached to the county network) where the control systems were located. That was the scary part about it like most of these pen test is that there was nothing james bond or interesting to it really. Sure plenty of the specific control software used in these environments has security flaws also but that does not matter when its an unpatched Windows 2000 system etc. ” Email from Marc Maiffret, April 18, 2011.

80. Global Energy Cyberattacks: “Night Dragon” white paper by McAfee Foundstone Professional Services and McAfee Labs, February 10, 2011.

81. A worm is a self-replicating program that, unlike a virus, does not have to infect a file to cause damage. Since many malicious programs these days utilize the features of worms and viruses, and also of trojans (which disguise themselves and non-malicious programs), the generic term “malware” is usually used.

82. W.32 Stuxnet Dossier, Version 1.4, February, 2011. Symantec Corporation . 83. Vulnerability Trends–SCADA Vulnerabilities, Symantec. http://www.symantec.com/business

/threatreport/topic.jsp?id 5 vulnerability_trends&aid 5 scada_vulnerabilities 84. “ 34 SCADA vulnerabilities revealed, ” Help Net Security, March 22, 2011. http://www.net

-security.org/secworld.php?id 5 10771 85. For example, see: Statement for the Record of Sean P. McGurk Acting Director, National

Cybersecurity and Communications Integration Center Office of Cybersecurity and Communications National Protection and Programs Directorate Department of Homeland Security Before the United States Senate Homeland Security and Governmental Affairs Committee, Washington, DC, November 17, 2010 .

86. “ Son-of-Stuxnet”–Coming Soon to a SCADA or PLC System near you ”. Eric Byres, May 31, 2011. http://www.tofinosecurity.com/blog/%E2%80%9Cson-stuxnet%E2%80%9D-coming-soon-scada-or-plc-system-near-you

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87. Dennis C. Blair, Director of National Intelligence, “Annual Threat Assessment of the U.S. Intelligence Community for the Senate Select Committee on Intelligence,” Statement for the Record, (February 2, 2010). Online at http://ww.dni.gov/testimonies/20100202_testimony.pdf

88. CIA -- Unclassified responses to the Questions for the Record from the Worldwide Threat Hearing on 6 February 2002, Senate Select Committee on Intelligence. http://www.fas.org/irp/congress/2002_hr/020602cia.html

89. Cyberterrorism Hype v. Fact, by Robert K. Knake, Council on Foreign Relations, February 16, 2010. http://www.cfr.org/terrorism-and-technology/cyberterrorism-hype-v-fact/p21434

90. A view of cyberterrorism five years later, Dorothy Denning, Center on Terrorism and Irregular Warfare, Naval Postgraduate School, Chapter 7 in Internet Security: Hacking, Counterhacking and Society (K. Himma ed.) Joes and Bartlett Publishers, 2007. In two emails to the author on June 30, 2010, Denning said that “ I also haven’t seen anything to give me concern about the jihadists or change my overall assessment. . . . I would be very surprised if AQ has anything resembling a computer training center today. Maybe they did at one time, but it seems unlikely they would now. There are people who have associated themselves with AQ who have cyber skills, but I don’t think any of them have the kind of skills needed to launch a serious cyber attack against a water system or any other critical infrastructure. Most of their skills relate to putting stuff on websites and protecting their cyber activities using tools like Tor and encryption. The jihadist cyber attacks are pretty rudimentary, e.g., web defacements and DoS attacks. ”

91. Water Security Initiative Program Overview and Available Products, EPA Fact Sheet, 92. Tiemann, Mary , Safeguarding the Nation’s Drinking Water: EPA and Congressional Actions,

September 30, 2010. 93. Security Vulnerability Self-Assessment Guide for Small Drinking Water Systems, Association of

State Drinking Water Administrators National Rural Water Association May 30, 2002 94. Measuring Water Security Progress, L. Vance Taylor, AWWA Water Security Congress,

September 21, 2010, National Harbor, Maryland. 95. Ibid . 96. WaterISAC Fact Sheet. http://www.epa.gov/safewater/watersecurity/pubs/waterISACFact

Sheet.pdf 97. Control Systems Security Program, US-CERT, http://www.uscert.gov/control_systems

/satool.html 98. Protecting Our Water: Drinking Water Security in America After 9/11. American Water Works

Association, 2004. http://fortressteam.com/resources/watersecurity.pdf 99. Roadmap to Secure Control Systems in the Water Sector 100. Safeguarding the Nation’s Drinking Water: EPA and Congressional Actions, Updated

December 15, 2004, by Mary Tiemann, Congressional Research Service, RL31294. http://www.hsdl.org/?view&did 5 459643

101. EPA needs a better strategy to measure changes in the security of the nation’s infrastructure, EPA Inspector General report, September 11, 2003. http://www.epa.gov/oig/reports/2003/HomelandSecurityReport2003M00016.pdf

102. “ Estimated costs for conducting a large system vulnerability assessment range from approximately $100,000 to several million dollars, depending on the complexity of the system. Additional resources are required to develop or revise the utility’s emergency response plan. AWWA has estimated the total national cost to develop vulnerability assessments as required by the Bioterrorism Act to be approximately $500 million. ” Protecting our Water: Drinking Water Security in America After 9/11, American Water Works Association [no date]. http://fortressteam.com/resources/watersecurity.pdf

103. Nuzzo, Jennifer B. “The Biological Threat to U.S. Water Supplies: Toward a national water security policy,” Biosecurity and Bioterrorism: Biodefense Strategy, Practice, and Science, Volume 4, Number 2, pp. 147–159, 2006. Page 152.

104. Nuzzo, p. 157. 105. Ernest Lory, Stephen Cannon, Vincent Hock, Vicki VanBlaricum, and Sandra Cooper, “Potable

water contamination and countermeasures,” Naval Facilities Engineering Service Center, 2006. http://jocotas.natick.army.mil/ColPro_Papers/Hock.pdf

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